Thursday, November 29, 2012

Coal: EIS Scoping Comment No. 28

Does GPT mean Gambling Public Trust?

I am concerned that the GPT proposal represents nothing more than a deliberate depletion of publicly owned coal for speculative private gain, at needless sacrifice of the human and natural environment.When any plan seems too good to be true, often, it likely is!Since our country has an announced goal of energy independence, why allow the export of non-renewable resources like Powder River Basin Coal?Why not leave the coal unneeded for current domestic purposes in the ground for future emergencies, similar to we do with the strategic petroleum reserve?Temporary over-supply of coal, petroleum & oil, natural gas, bio-fuels from subsidized corn, and the like, has historically happened over time, so why not plan for it?Shouldn't our national energy policy be determined by the Federal Administration & Congress, not the wildly fluctuating global market involving 3rd-world countries?A good practice would be to pace ourselves, emphasize energy efficiency, conservation, and development of alternate, renewable sources?And, why would the US wish to weaken its future strength by quickly selling off its natural assets as non-value added commodities to its main competitor?Such unprecedented shortsightedness needs to be strongly questioned, both from a public policy point of view and as a risky investment that depends on windfall profits over a few years.Loss of coal resources, instability of promised tax revenues and jobs, impacts to public health & safety and degradation of the environment, all seem to exact a heavy price to pay for a private equity gamble masquerading as beneficial and sustainable, economic growth for the public.

While the Applicant's [SSA] other corporate collaborators are not risking significant capital themselves, SSA -backed by Goldman Sachs- really is taking a big risk. Peabody Coal will get paid by its Asian customers before it ships one lump of coal; BNSF will be paid for what it hauls on its tracks for Peabody; ultra-large Bulk Carriers will be paid before they take on any coal cargo for Peabody. But, GPT is the one critical facility for which substantial investment is essential, because without it being permitted, built and operated, none of the other transactions mentioned would become enabled, nor would SSA earn any revenues from its Cherry Point proposal.

I therefore request the MAP Team press this Applicant -SSA-Marine- for its pro forma expectations for payback to confirm or deny that GPT is truly a project meant to sustain itself for the long life expectancy it claims. While corporations and investors are free to take substantial monetary risks to earn higher returns, it is not healthy to collateralize those risks by foisting a deception upon local governments, citizens and the impacted natural environment. Solid, sustainable business is not usually predicated upon quicksand-like foundations, as the GPT proposal appears to be.